[SLIDESHOW] MIPS Year Two: 13 Things to Know

As October closed, CMS announced a new initiative called the “Patients Over Paperwork” initiative. The goal is to reduce the regulatory reporting burden put on clinicians. CMS wants to continue their transition to paying for value and quality, but redefine what it means to pay for value and quality. Their new initiative “aims to focus on outcome-based measures going forward, as opposed to trying to micromanage processes.”

In the same week, CMS dropped the Quality Payment Program (QPP) final rule for year two. This new initiative is reflected in the changes found within the 1,322-page final rule. Based on the new requirements, it’s clear that CMS is attempting to ease the transition into QPP for all clinicians and provide relief to small practices.

1. Eligibility Requirements

Eligibility requirements will change to make it easier for clinicians to be exempt from MIPS reporting. The same titles are eligible – Physician, Physician Assistant, Nurse Practitioner, Clinical Nurse Specialist, Certified Registered Nurse Anesthetist. In addition to these job titles the clinician must:

Bill Medicare more than $90,000 in allowable charges ORsee more than 200 Medicare Part B patients.

Last year, clinicians were excluded if they billed Medicare less than $30,000 or saw less than 100 Medicare Part B patients. This change will exclude more clinicians from reporting in 2018.

2. EHR Technology

CMS did a good job of scaring everyone into thinking they had to be ready to use the 2015 Edition of Certified EHR Technology (CEHRT) in 2018. In the final rule, however, they have backed away from that requirement, now permitting Eligible Clinicians to still use the 2014 Edition instead. While it’s no longer a requirement, CMS is encouraging the use of 2015 CEHRT with a nice 10 percent bonus in the ACI category for those who exclusively use the 2015 Edition.

3. Category Weighting

In the proposed rule, CMS said they would keep the categories weighted the same as they were in 2017. However, in the final rule they changed their mind, stating that it would make the transition to 30 percent weight for Cost in 2019 more difficult. So in 2018, the Cost category will be weighted 10 percent of the final score. Which means there is a change in the Quality category as well. The Quality category has bumped down from 60 to 50 percent of the total score. Here are the category weightings for 2018.

4. Category Requirements

The only change comes within the Cost category. CMS will not use the 10 episode-based measures that are used for the 2017 MIPS performance period. The Cost category will only include the Medicare Spending per Beneficiary (MSPB) and total per capita cost measures in 2018.

All other categories - Quality, IA and ACI, do not have requirement changes. CMS has modified and added several measures in each category.

5. Reporting Options

No longer can you “Pick Your Pace” for reporting to MIPS. For the Quality and Cost categories you must submit 365 days of data. For the Improvement Activities (IA) and Advancing Care Information (ACI) categories you must submit a minimum of 90 days of data.

6. Quality Data Completeness

In 2017, all of the Quality measures that you submit must contain at least 50 percent of all Eligible Clinician patients across all payers. In 2018 this percentage is upped to 60 percent. If your measure fails this requirement you will earn only one point for that measure, instead of the possible 10 points.

If, however, you are considered a small practice, you will still earn a minimum of three points for each Quality measure submitted regardless of the percentage of patients included.

7. Performance Threshold

You must achieve at least 15 points to avoid a negative five percent penalty in 2018. That’s up from the three-point minimum of 2017. In the graph below, you’ll see the performance threshold minimum at 15 points and the performance threshold for exceptional performance at 70 points. Once you hit that 70-point threshold you will earn bonus money on top of any money you make from scoring above the 15-point threshold score.

8. Payment Possibilities

And speaking of money, as I mentioned above, you can get up to five percent added to your Medicare reimbursement funds by performing well in MIPS next year. Conversely, you can expect to receive a negative five percent reduction to your Medicare reimbursement funds if you don’t meet that 15-point performance threshold score.

11. Virtual Groups

New this year is the concept of Virtual Groups, which will allow individual clinicians and small groups to come together to form one virtual group that can report together. Clinicians do not need to be in the same area of the country or be in a similar specialty to be in the same group. All members of the virtual group must be Eligible Clinicians either at an individual level or a group level.

12. Improvement Bonus

Another nice little bonus will be awarded to any clinicians whose Quality or Cost score has improved over last year (pending there is enough data for comparison). You can receive up to 10 bonus points in the Quality category and one additional bonus point in the Cost category. Keep in mind, CMS will figure an improvement score only when there's sufficient data to measure improvement. So make sure to submit your data for 2017!

WEBINAR:

TIPS FOR MIPS YEAR 2: A GUIDE TO THE 2018 QUALITY PAYMENT PROGRAM

MARCH 14, 20181 P.M. ET | 12 NOON CT | 10 A.M. PT

Are your providers ready to meet their MIPS reporting requirements? This free educational webinar will help you understand the MIPS program structure and requirements.

You’ll learn the basics of the Quality Payment Program (QPP) and the specifics of what’s required for successful completion of MIPS. We will outline strategies that will help you prepare your providers for their best reporting year yet.